Legal information
Privacy policy
Trust also rests on clear information.
Privacy policy of kaplim.eu (Brussels time). It describes the processing of the waiting list, now in service, and the processing contemplated for subscriptions, which are not yet open. The French version is authoritative. In the event of any discrepancy, the French text shall prevail.
1. Controller
Pierre Galle, sole proprietorship (entreprise personnelle) trading as Nataru Labs, BCE / TVA BE 1044.922.107. Privacy contact: contact@kaplim.eu. No data protection officer has been appointed at this stage; the need to appoint one will be assessed in the light of the processing actually carried out.
2. What remains local: the simulator
The public simulator runs exclusively in the memory of your browser. No check is transmitted. No application cookie, persistent local storage, account or advertising profile is created for this function. The dated record and the register are reserved for houses on the waiting list and are not offered in the public demo.
Fonts and visuals are served locally: there is no call to Google Fonts. No Google Analytics or other audience-measurement tool is included. If you follow a link to a legal source, the external site receives the visit and applies its own policy.
3. Waiting list
When you submit the registration form, Nataru Labs (Pierre Galle, entreprise personnelle, BCE / TVA BE 1044.922.107), as controller, collects the information you provide in order to compile a waiting list of interested shops. Registrations are recorded on the kaplim.eu server and consulted by Nataru Labs through its central administration.
Purpose. To inform you of the opening of Kaplim, to reserve for you the launch offer of −50% for 3 months, and to understand more clearly the profile of the houses that are interested (type of shop, country, number of stores). Registration is not an order and involves no payment.
Data. E-mail (required); shop name (optional); type of shop; country; number of stores; date and time the form was displayed; and, where applicable, minimal technical data linked to the submission (for example an error log or rate limiting). No identity document is requested.
Confirmation e-mail. After each new valid registration, a confirmation e-mail is sent to the address provided. This message is not a marketing mailing: it only confirms the registration, recalls the information submitted and the launch offer presented at the time of registration, and includes an unsubscribe link. An internal notification is also sent to contact@kaplim.eu.
Legal basis. Your consent (Article 6(1)(a) GDPR), collected through an unticked box, which you may withdraw at any time, without affecting the lawfulness of processing already carried out.
Retention period. Retention for up to 24 months after the waiting list is closed, or until you withdraw your consent if that happens sooner, followed by erasure or anonymisation, unless a legal obligation requires otherwise.
Unsubscribing and your rights. To withdraw your consent or to exercise your rights (access, rectification, erasure, restriction, portability where applicable, objection), please write to contact@kaplim.eu. An unsubscribe option will also be recalled in information messages. You may lodge a complaint with the Belgian Data Protection Authority or with the competent authority of your place of residence.
4. Processing contemplated for the subscription service
| Purpose | Minimum data contemplated | Legal basis contemplated |
|---|---|---|
| Waiting list and information on the opening (see section 3) | E-mail, shop name where provided, type, country, number of stores, consent and timestamp | Consent, withdrawable at any time |
| B2B account and subscription | Professional identity, contact details, authorisations, invoicing and payment references | Performance of the contract; legal obligations for invoicing; a documented legitimate interest for professional contacts who are not party to the contract |
| Security and support | Strictly necessary technical logs, IP address where justified, support correspondence | Legitimate interest in securing the service and handling requests, after an assessment of the interests involved |
| Register of the shop’s checks | Country, amounts, date, rule, result and salesperson identifier; an internal pseudonymous reference if needed | Instructions of the shop, as controller, under a processor agreement (Article 28 GDPR) |
This table is prospective. The service must not be activated before each purpose, basis, category and recipient has been confirmed. Mandatory fields and the consequences of not providing a response will have to be clearly indicated at the time of collection.
5. Minimisation
The calculation does not need the end customer’s name, passport number, photograph or a copy of a document. Please do not add sensitive data or supporting documents in a free-text field. The shop handles separately, under its own responsibility, the documents that the law requires it to check and to keep.
6. Retention periods
For the waiting list, see the period stated in section 3 (24 months after the list is closed, or until consent is withdrawn).
The periods applicable to accounts, the register, support, invoices, security logs and backup rotation will be specified when subscriptions open. They will be limited to the purpose, to the applicable legal obligations and to proportionate needs of proof.
For the public simulator: browser memory until the page is reloaded or closed. No file is created by the demo. Any records or exports later offered to houses on the waiting list cannot be erased remotely by Kaplim once they have been downloaded or printed.
7. Recipients and hosting
Waiting-list registrations are recorded on the kaplim.eu server and consulted by Nataru Labs through its central administration. The site is hosted by OVHcloud (OVH SAS, 2 rue Kellermann, 59100 Roubaix, France), on a server located in Beauharnois (Quebec, Canada). Contact e-mails are sent through Forward Email. The payment provider will be specified when subscriptions open. Only authorised staff and necessary providers, bound by contract, should have access. The data are not intended to be sold.
Hosting. The kaplim.eu site and the waiting-list registrations are hosted by OVHcloud on a server in Beauharnois (Quebec, Canada). This transfer outside the European Economic Area is framed by the European Commission’s adequacy decision relating to Canada (Decision 2002/2/EC), which recognises an adequate level of protection for organisations subject to the Canadian PIPEDA legislation. Hosting in the European Union may be considered later; this policy will then be updated.
The sending of contact e-mails and of waiting-list confirmation e-mails is handled by Forward Email.
8. Security and central administration
The site is served over HTTPS. Administration of registrations is carried out by Nataru Labs through its central administration. Security measures (restricted access, backups, proportionate logging, updates and incident handling) are being put in place progressively and do not constitute a certification.
In the event of a personal-data breach in the future service, a procedure will need to make it possible to assess the risk, to inform the controller and, where the GDPR so requires, the authority and the persons concerned within the applicable time limits.
9. Your rights
Under the conditions of the GDPR: access, rectification, erasure, restriction, portability where applicable, objection to processing based on legitimate interest, and objection to direct marketing. You may withdraw your consent at any time without affecting the lawfulness of earlier processing. No automated decision-making producing a legal effect is contemplated: the simulator assists a human decision.
To exercise your rights, please write to contact@kaplim.eu. A proportionate identity check may be requested where there is reasonable doubt, without any systematic collection of an identity document. A reply will in principle be given within one month; a reasoned extension may be applied under the conditions of the GDPR. For data in a register kept by a shop, please contact that shop first; Kaplim will have to assist it as a processor.
10. Complaints
You may lodge a complaint with the Belgian Data Protection Authority, or with the competent authority of your habitual residence, place of work or place of the alleged infringement.
11. Cookies, changes and contact
No cookie banner is needed so long as no tracker is used. If central authentication adds necessary cookies, they will have to be documented; any non-essential tracker will require information and, where required, prior consent. No analytics tool will be added silently. This policy will be updated whenever a substantial change is made.